Jospeh Judkins

Joseph (Jud) B. Judkins

Partner
Baker & McKenzie LLP

Biography

Joseph "Jud" Judkins is a partner in Baker McKenzie’s Tax Practice Group and serves on the group’s Tax Controversy Steering Committee. Jud focuses on federal tax controversy matters at every phase of a dispute, including audit, IRS Appeals, and litigation. The application of administrative law principles to Treasury regulations and IRS guidance is a core component of his practice. Jud advises clients on a broad spectrum of international and domestic tax matters, including challenges to the validity of regulations, participation in the agency rulemaking process through the submission of comments and testimony at public hearings, the scope and application of TCJA regulations, transfer pricing disputes, tax statutory and regulatory interpretation, and other domestic and international tax issues. Jud previously clerked at the US Tax Court and served in the US Navy JAG Corps.

Practice Focus

Jud concentrates on tax dispute resolution.

Representative Legal Matters

  • Altera Corp. & Subsidiaries v. Commissioner, 145 T.C. No. 3 (2015), rev’d, 926 F.3d 1061 (9th Cir. 2019) (challenge to the validity of transfer pricing regulations).

  • Guardian Industries Corp. v. United States, US District Court for the District of Michigan, No. 4:16-cv-1911 (suit for refund of penalties for failure to file information returns of foreign corporations).

  • Gubser v. Internal Revenue Service, US District Court for the Southern District of Texas, No. 5:15-cv-00298, US Court of Appeals for Fifth Circuit, No. 16-40948 (declaratory judgment suit regarding the standard for proving a willful FBAR penalty).

  • Maze v. Internal Revenue Service, US District Court for the District of Columbia, No. 1:15-cv-01806, US Court of Appeals for the D.C. Circuit, No. 16-70496 (suit challenging the validity of rules under the Offshore Voluntary Disclosure Program).

Admissions

  • U.S. Supreme Court~United States (2016)
  • U.S. Court of Appeals, Ninth Circuit~United States (2016)
  • U.S. Court of Appeals, Fifth Circuit~United States (2016)
  • U.S. District Court, Eastern District of Michigan~United States (2016)
  • U.S. District Court, District of Columbia~United States (2015)
  • Tennessee~United States (2014)
  • U.S. Tax Court~United States (2009)
  • District of Columbia~United States (2006)
  • North Carolina~United States (1999)

Education

  • Georgetown University (LL.M. Taxation Distinction) (2008)
  • Wake Forest University (J.D. cum laude) (1999)
  • University of Tennessee (B.A. summa cum laude) (1996)

Languages

  • English

Publications

  • Author, “The Rise of Footnote 9 (And Why Some TCJA Regulations Fail Chevron Step One),” TAXES the Tax Magazine, March 2020

  • Co-author, "Chamber of Commerce Shows the Vulnerability of In Terrorem IRS Notices," TAXES the Tax Magazine, March 2018

  • Co-author, "Treasury Issues Temporary and Final Code Section 385 Regulations," Baker & McKenzie, Tax News and Developments Client Alert, November 2016

  • Co-author, "GAO’s Report on Treasury and the IRS’s Regulatory Guidance Process," Baker & McKenzie, Tax News and Developments Client Alert, October 2016

  • Co-author, "Tax Court Invalidates Treasury Regulation in Altera," Baker & McKenzie, Tax News And Developments Newsletter, August 2015